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Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustment.
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....Tribunal considered selection of the appropriate tested party for transfer pricing and held the taxpayer's diamond division is the least complex entity and therefore the appropriate tested party; this conclusion rested on functional analysis showing the division performed routine buying, assortment and sales with modest assets and workforce, and on the fact the TPO accepted the same unit as tested party in a subsequent assessment year. The decision also notes authority that foreign associated enterprises are not precluded from being tested parties where they are less complex than the taxpayer.....